A consultation on a DVLA Trial of Smart Card Provisional Driving Licences was run with with a closing date of 11/01/2008.
I responded to the consultation, answering all their questions with the below:
Question 1: Do you understand and agree with the trial approach?
” Drivers will still control access to the data on the microchip in the same way as they control sight of the printed data, so no data protection issues are raised. “
I disagree with that statement.
i/ When someone reads printed data they do not generally retain a copy, if they do take a photocopy, or manually read or key in data it is usually obvious. When data on a chip is read it is not clear to the owner of the chip if it has been retained or not. I think that does raise a data protection/privacy issue.
ii/ Also the statement that access to data on the chip is controlled by the holder in the same was as if it was printed is clearly not the case for cards that can be queried and respond in a contactless manner using radio frequencies. In this respect the consultation document is highly misleading and inconsistent. The concept of data on the chip being under the control of the license holder is something repeated throughout the consultation document, if the chip can be queried in a contactless manner this is not the case.
If I put my contactless card in an envelope (or the DVLA does as it is delivered to me) the chip can still be read, even if the writing on the card cannot.
“There is growing concern about the misuse of driving licences, particularly in respect of the number of driving test candidates that are represented fraudulently.”
I disagree that making the provisional license harder to forge, or providing a larger photo on a chip on the license card are sensible responses to this problem.
I believe a more rational response would be to make it easier for test centers, (and courts, the police etc.) to check the veracity of licenses. Why not let them download a good quality picture online for example, or confirm online that all the data elements on the license match. All that would be needed if validation was easy is for the DVLA to issue a number, which could even be sent by text message, email or over the web. I can see a chip could be used in such a way as to provide proof a particular license was present in a particular location and this would add to security, however this does not appear to be the prime use of the chip in this trial.
Question 2: Do you agree with the reasons for restricting the trial to Welsh Provisional Driving Licences?
The arguments given could have applied to any region. On the basis of what is stated in the consultation document you could have picked any postcode region or set of postcodes. This leads me to suspect that you have chosen Wales for an undisclosed reason. (Perhaps you already print their licenses separately?) You mention maintaining only two parallel formats under “legislative cover” but it is not clear to me why you are limited to two formats.
Question 3: Do you agree that only the information printed on the face of the card should be written to the microchip?
No, and this isn’t going to be the case if the quality of the image is to be better on the chip, if the quality of the image is greater then more information is present. One of the main points of the trial would be missed if the information within the photo on the chip was not better than that printed on the card. While this is noted in the consultation document, the summary which misses this is repeated lots, as it is in this question and so becomes misleading.
In terms of the printed information I agree, but note the sample license card shown in the consultation document does not include a place of birth. Place of birth is however included on the list of details shown printed on the license, this appears to me to be another inconsistency.
Question 4: Do you agree that the ‘microchip’ should be rendered read-only?
That’s how you’ve decided to limit the trial in the first instance, I see no problem with that, though it might be seen as dishonest and misleading if your intention in the future is to have re-writable chips, or re-writable elements of chips. You might be keen to get a good result out of the trial so avoiding trialing an aspect in which you have less confidence. If the final licenses are to have rewritable chips then that’s what I think you should trial.
Question 5: Do you think the Departmental route for funding is most appropriate?
I find the funding information in the consultation document revealing you already have the ability to produce these chipped driving licenses at almost no extra cost disconcerting, it implies the decision to make and use them has already been made and this consultation is a sham.
Clearly the provisional license applicants of Wales shouldn’t pay for this project on their own.
Question 6: Do you consider that the risks identified have been assessed correctly?
I agree the trial is small, and limited by time and geography and that results in a small financial risk. I can see that the licences will function as they did before without the chips if the chips don’t work, so that makes it a low risk trial. However I can’t see any evidence in the consultation document that the risk of affecting people’s views of the proposed ID card have been assessed, though the potential sensitivity has been noted.
Question 7: Do you think there are risks that we have not identified?
The risk assessment fails to account for a loss in confidence in the Government, Government’s ability to run IT systems, and Government’s ability to run ID card systems if the trial fails.
The risk assessment does not consider the effects of making predominantly young people hold these chip cards if they want to drive when those, largely older with full licensees are not involved in the trial. Might the trial affect the view of the state that young people have which will affect their interaction with it for the rest of their lives, getting a provisional license for many people might be one of their first interactions with the state and these proposals make it all more big-brotheresque.
Potential privacy issues with a contactless card have not been appreciated.
The consequences of the poorer quality – black and white only photo on the card ittself have not been addressed. Will this make it harder to use the card for other purposes for which photo-id is required? Will the black and white photo it make it harder for those police or examiners who don’t have access to card readers to assure themselves the person in front of them is the person on the licence?
Question 8: Do you think remote authentication will be of benefit to drivers and / or to the commercial companies with whom they interact? What uses would be most beneficial?
I think a “chip and pin” style of usage is unlikely to work. I only know the pin numbers I do because I use them regularly. I feel it unlikely that if I created a PIN number for my driving license I would remember it when needed, perhaps many decades after it was created without any need to recall it or use it in the intervening period.
I do not see a problem with insurance companies working as they currently do, involving a chip and pin is just adding complexity without as far as I can see adding any benefit.
I do not see the need for a PIN, if the license card is present (as confirmed by querying the chip) then I don’t see the problem with allowing a query of the DVLA’s systems for any endorsements.
Question 9: Do you think electronic transfer of microchip data under the control of individual drivers would be beneficial?
Yes, but it raises the question of why the Police, DVLA and Courts use different systems that need the same information moving from one to another in the first place. Why not fix the larger problem. I agree that at the most basic level, reading an identifying number off the card automatically rather than manually is a good idea.
Question 10: Would you like to see a facility to record optional (non-driver related) data on the microchip if the cardholder had a choice on what data they wanted included and the data was held in a separate, secure, re-writeable area on the microchip?
No. I think driving licenses should be for driving related information. I don’t want all my eggs in one basket. I don’t want a mistake with the DVLA affecting other areas of my life. I don’t think the DVLA should get into trying to keep my medical records, or my will.
Question 11: What data do you think would be useful?
If you are going to have a chip, to confirm the presence of the card. Just the high resolution photograph and an identifying number on the chip would suffice, anything else could be gained online from the DVLA.
Question 12: Do you think the address should be on the card and the microchip, the microchip only or stored only by DVLA on the main database?
I see no reason why if people don’t what their address on the card it needs to be there.
Question 13: Would you see this optional (but chargeable) retention of address on the Driving Licence as an attractive or viable option to pursue?
I see no reason why if people don’t what their address on the card it needs to be there. I think the option should be given at the time of application/renewal and cannot see why it needs to be specifically charged for unless a new card is to be printed specifically to make this change.
Will participation in the trial be voluntary? It appears not but why not state this more clearly?
Will those issued with chips which can be queried by radio be given full information about their capabilities, eg. in what circumstances they could be read and what information could be extracted from them without their knowledge.
I am concerned that you are forcing predominantly young people into carrying ID cards. Is the DVLA being used to soften people up to the idea of ID cards?
Why are the courts not included in those to be involved in this trial?
Why are qualitative terms like “life size” and “colour image” used in the consultation document to describe the photograph to be held on the chip. Many people now have experience of working with digital photographs on their phones, computers and cameras, we can understand resolution, size in pixels, data formats, and compression so why not give us the details?
While the consultation document doesn’t say they will be explicitly invited to be involved in the trial could other organisations such as supermarkets (who could gain information about who is using their store and what they are buying) or pubs acquire a capability to read the cards (will alarms go off as Welsh under 18s carrying their chipped licences try and enter licensed premises for example?).
Will the chip readers be “online”. Will they have a connection to the DVLA? That most basic level of detail is not available in the consultation document.